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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. SBR 0315782
Regular
Jul 30, 2007

GORDON ADAMS vs. SOUTHLAND DRYWALL COMPANY, STATE COMPENSATION INSURANCE FUND

This case concerns a lien claimant, Premier Outpatient Surgery Center, Inc., whose lien was denied because it allegedly did not use its full corporate name or have a fictitious business name permit. The Appeals Board rescinded the denial and returned the case for further proceedings, finding that Premier was properly licensed as an outpatient facility and that the defendant did not timely raise the fictitious business name statement issue. The Board clarified that a facility fee lien claimant is not required to have a Medical Board fictitious-name permit, but may need to file a fictitious business name statement if operating under a name other than its legal corporate name.

Workers Compensation Appeals BoardLien ClaimantFictitious Business Name StatementFictitious-Name PermitBusiness & Professions Code Section 17910Business & Professions Code Section 2415(a)Medical Board of CaliforniaOutpatient SettingFacility FeeCompromise and Release
References
Case No. LAO 0878674
Regular
Mar 06, 2008

KARLA BUENO vs. PLAZA DEFENDANT LA RAZA, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a decision that barred a lien claim due to the alleged lack of a fictitious business name permit. The WCAB found that while the lien claimant presented a surgical clinic license, the record was unclear about its actual business name and compliance with fictitious name filing requirements. The case is remanded for further proceedings to determine the lien claimant's true name and establish its compliance with fictitious business name laws.

Fictitious Business Name StatementSurgical Clinic LicenseHealth ServicesBusiness and Professions CodeMedical BoardLien ClaimantOutpatient SettingAdministrative Law JudgeReconsiderationReasonableness of Fees
References
Case No. STK 0189570
Regular
Jul 30, 2007

JOSEPH BUENO vs. AMERICAN FIRE SYSTEMS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board affirmed the administrative law judge's decision, allowing a lien claim of $10,838.43 for facility fees. The defendant argued the lien should be disallowed due to the lien claimant's alleged lack of a fictitious name permit. However, the Board found the lien claimant met its burden of proof by demonstrating proper licensure and that it was not operating under a fictitious name, thus not requiring a fictitious name permit from the Medical Board.

Workers Compensation Appeals BoardLien claimantFictitious name permitMedical Board of CaliforniaFacility feesArthroscopic surgeryStipulated awardPermanent disabilityFuture medical treatmentAmbulatory surgical centers
References
Case No. ADJ10430501
Regular
Aug 05, 2019

MARCO ESTRADA vs. INCA ONE CORP, REPUBLIC INDEMNITY COMPANY OF AMERICA

The Workers' Compensation Appeals Board denied a lien claimant's petition for reconsideration. The claimant failed to prove it possessed a valid fictitious business name permit at the time services were rendered, a requirement for maintaining its lien. While the claimant argued they cured the defect, the Board found they did not meet their burden of proof and the FNP status remained canceled. The decision upholds that lien claimants must demonstrate compliance with applicable licensure and permit requirements.

Fictitious Business Name PermitBusiness and Professions Code Section 2415Burden of ProofLien ClaimantMedical Board of CaliforniaSecretary of StateFictitious Name PermitComplianceCurable DefectPetition for Reconsideration
References
Case No. LAO 0819419, LAO 0819420
Regular
Mar 06, 2008

RUBEN MARQUEZ vs. HOLLYWOOD GLASS COMPANY, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration, rescinded the prior order disallowing the lien claim of S&B Surgery Center, and remanded the case for further proceedings. The Board found that while S&B Surgery Center likely met licensing requirements for its services, it needed to establish proper compliance with fictitious business name statement requirements or amend its claim to reflect its true corporate name. The case is to be returned to the trial level to address these issues and redetermine the reasonable value of S&B's services.

Fictitious Business NameLien ClaimantLicensing StatusSurgical Clinic LicenseBusiness and Professions Code Section 17910Outpatient SettingMedical BoardDepartment of Health ServicesBurden of ProofReasonable Fee
References
Case No. ANA 0356755
Regular
Aug 22, 2007

YAZMINA VERDUZCO vs. EXECUTIVE AIR WASH, INC., STATE COMPENSATION INSURANCE FUND

This case involves a lien claim by Outpatient Spine & Surgery Center (OSSC) for over $74,000 in surgical services. The original ruling disallowed the lien, finding OSSC failed to prove it had a fictitious name permit from the Medical Board. The Appeals Board rescinded this decision, remanding the case for further proceedings to determine OSSC's compliance with licensure and accreditation requirements and the reasonableness of its charges.

Fictitious Name PermitMedical BoardLien ClaimantOutpatient SettingAccreditationBusiness and Professions CodeLicensureBurden of ProofRescindReturn to Trial Level
References
Case No. SBR 0311485
Regular
Jun 28, 2006

KIMBERLY STOKES vs. PATTON STATE HOSPITAL / DEPARTMENT OF MENTAL HEALTH / STATE OF CALIFORNIA, legally uninsured, administered by STATE COMPENSATION INSURANCE FUND

This case concerns the lien claim of Ambulatory Surgery Center of Pomona (ASCP) for services rendered to an injured worker. The prior decision disallowed the lien because ASCP lacked a fictitious-name permit from the Medical Board of California. ASCP argues a permit wasn't required for "facility fees" and it possessed necessary accreditations. The Appeals Board rescinded the decision, remanding for a determination of whether ASCP operated as a "clinic" requiring a permit or an "outpatient setting" exempt from such if accredited, and whether its accreditation was valid for ASCP.

Fictitious-name permitMedical BoardAmbulatory Surgery CenterClinicOutpatient settingAccreditationBusiness and Professions CodeHealth and Safety CodeLien claimantProfessional services
References
Case No. ANA 381864
Regular
Feb 25, 2008

TUAN KHANH DO vs. CONEYBEARE PERSONNEL SERVICES, STATE COMPENSATION INSURANCE FUND

This case concerns a Qualified Medical Examiner's (QME) entitlement to payment for medical-legal services. The defendant insurer argued that the QME's lien claim was invalid due to the use of a business name without a fictitious business name permit. However, the Workers' Compensation Appeals Board denied reconsideration, finding the QME rendered services and signed reports under his own name. The Board further noted that the insurer failed to properly object to the billings within the regulatory timeframe and the lien claim form was amended to reflect the QME's individual name.

WCABState Compensation Insurance FundMedical-legal servicesFictitious business name permitQualified Medical ExaminerLien claimCompromise and releaseMedical Board of CaliforniaBusiness and Professions CodeLabor Code
References
Case No. LAO 0794643
Regular
May 07, 2008

FRANCISCO CHAPA vs. GIBSON OVERSEAS, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration, rescinding the initial denial of a lien claim by S&B Surgery Center. The Board found the record insufficient regarding S&B's licensure and proper business naming, remanding the case for further development. This includes proving proper licensure as an "outpatient setting" and addressing the necessity of filing a fictitious business name statement, followed by a determination of the reasonableness of the billed fees.

Lien claimantreconsiderationlicensurefictitious business name statementoutpatient settingsurgical clinicMedical Boardcounty clerkreasonableness of feesburden of proof
References
Case No. ADJ2403362 (MON 0247582) ADJ2066217 (MON 0306486)
Regular
Apr 25, 2011

EMILIA MENDOZA vs. LACMTA, THE TRAVELERS INS. CO., LOS ANGELES METROPOLITAN AUTHORITY, CONSTITUTION STATE SERVICES COMPANY

The Workers' Compensation Appeals Board affirmed the disallowance of lien claimant Care Center Rehabilitation and Pain Management's (LC) lien for unpaid medical treatment. LC failed to file a required fictitious business name statement and could not prove the treatment was reasonable and necessary. However, the Board reversed the order for LC to pay restitution to the defendants, finding they failed to meet their burden of proof for unjust enrichment.

Workers' Compensation Appeals BoardEmilia MendozaLACMTAThe Travelers Insurance CompanyConstitution State Services Companylien claimantCare Center Rehabilitation and Pain Managementindustrial injuriesneck and shouldersbus operator
References
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